Qairokkum HPP Rehabilitation

Qairokkum HPP - Rehabilitation Project (I) Non-Technical Summary (II) Stakeholder Engagement Plan (III) Environmental and Social Action Plan Page 1

(I) Non-Technical Summary Description of the Qairokkum Hydropower Rehabilitation Project This non-technical summary aims at providing the public with a description of the Qairokkum Hydropower Rehabilitation Project (the Project ) undertaken by Barki Tojik. The present document is made available to the public by Barki Tojik in Tajik, Russian and English languages. The Qairokkum hydropower plant has been constructed in the 1950s. Most of the electric and mechanical equipment of Qairokkum hydropower plant has reached the end of its lifetime, therefore a major rehabilitation is needed. The objective of the rehabilitation and upgrading of Qairokkum hydropower plant is threefold: a) Rehabilitation and upgrade of the energy generation under present and future climatic conditions, b) Raising the safety standards of the power plant, concrete dam and reservoir to international standards, and c) Strengthening the resilience of the hydropower plant against climate change effects. In the course of the technical evaluation, several options were discussed and prioritized for immediate implementation. Based on a multi-criteria analysis, it was decided to further pursue as a priority the option of 6 new vertical Kaplan turbines to be custom fit into the existing power house. This replacement requires only minor adaptations of the structure. For the rehabilitation of the spillway gates, turbine intake stop logs, trash rack and trash rack cleaning machine and the draft tube stop logs, different options have been looked at during the prefeasibility stage. It was concluded to implement as a priority the rehabilitation and the installation of automatic drives on two of the spillway gates and restore the remaining ones. The trash rack will be replaced, including the installation of an automatic self-driving cleaning machine. This way trash removal can be done in the future during normal operation and without shutting down turbines. Most of the electric installations also have to be renewed since they have reached the end of the lifetime. New generators are needed for the installed capacity. A new automatic control system will be installed and the monitoring and surveillance system, including an alarm system for the embankment dam, will be integrated. The power house and weir structure will need some adaptation and some repair where the surface concrete is eroded and armor steel is exposed. Environmental and social impacts The Qairokkum Hydropower Rehabilitation Project will have local and small scale negative environmental and social impacts only, mainly during the construction period. Most of the negative impacts Page 2

that are usually associated with new hydropower plant projects will be avoided, since there is: no erection of a new dam, no raising of the reservoir water level, no inundation of settlements or fields, no land acquisition or resettlement, no changing in the minimum flow rate, no increased sedimentation, no increased erosion risk, no large construction site. Instead the project encompasses several positive impacts, mainly related to safety issues: A central structure in the power plant are the two gantry cranes: they are used to operate the spillway gates in case of high water. Above mentioned measures aim to refurbish those cranes and facilitate operation also in emergency situations; General plant safety and certainty of operation are being improved by automatization of the equipment (see above); Worker safety will be improved by automatization or remote controlling of the gates; The concrete dam will be equipped with additional surveillance devices; The Project will result in an increase of electricity generation (more efficient turbines will be used) and an improved level of service (the risks of production disruptions will be reduced) In addition, the Project also has expected positive environmental and social impacts: The new turbines and generators will lead to an increase in electricity production by 20%, thus reducing the respective amount of greenhouse gas emissions from national electricity generation; Oil leakage sumps will catch spilled oil and the new system will need less oil overall; Barki Tojik will assess the interest and possibility to introduce new turbines that would be fish-friendly, in order to decrease the mortality of aquatic life passing the turbines. The social impacts expected from the Project include: The need for workers during the construction activities; Potential for training on new equipment; The increased quantity and security of electricity production, and Increased public safety with regards to the dam associated risks. Stakeholder engagement Page 3

The Project is viewed as an opportunity to enhance stakeholder engagement at the facility level. A Stakeholder Engagement Plan was put in place by Barki Tojik in order to ensure public information during the Project implementation. The key stakeholder engagement actions undertaken include: The information of the public about the Project; The introduction of a grievance mechanism; The introduction of environmental information sharing at the facility level. Page 4

(II) Stakeholder Engagement Plan 1. Introduction The present Stakeholder Engagement Plan (SEP) was prepared by Barki Tojik for the Qairokkum HPP Rehabilitation Project. The SEP meets the requirements of EBRD 2008 Environmental and Social Policy. Based on the EBRD s Environmental and Social Policy - Performance 10: Information Disclosure and Stakeholder Engagement, the stakeholder engagement is an ongoing process involving the client s public disclosure of appropriate information to enable a meaningful consultation of stakeholders advising of potentially affected parties a procedure or policy by which people can make comments or complaints This process should begin at the earliest stage- the project planning phase and continues throughout the entire project. This Performance outlines a systematic approach of stakeholder engagement that will help clients to build and maintain a constructive relationship with their stakeholders, in particular the locally affected communities. The process of stakeholder engagement is an essential component of the appraisal, besides management and monitoring of environmental and social issues. EBRD requirements for stakeholder engagement Due to EBRD involvement in the Qairokkum HPP reconstruction, the Project must meet the high international standards and their requirements, which are specified in the PR10 of the EBRD Environmental and Social Policy. The EBRD considers stakeholder engagement as an essential part of good business practices and corporate citizenship, and a way of improving the quality of projects. In particular, effective community engagement is essential for a successful management of risks and impacts on communities that are affected by projects. Furthermore the engagement is an useful instrument, which leads also to benefits for the society. In this stage of the Project the following procedure of a stakeholder engagement could be applicable to Qairokkum HPP project: Stakeholders identification. This is the first step in the stakeholder engagement plan where everyone who might be affected by the Project in terms of construction and operation, will be identified. This includes local residents, members of the government, administration bodies, private companies, NGOs and the general public. Page 1

Process of stakeholder engagement and information disclosure. In this phase the client has to ensure an appropriate engagement of the identified stakeholders through proper information disclosure and meaningful consultation. Meaningful consultation. The actual process of consultation will consist of the widely accessible disclosure of information relevant to Qairokkum HPP and clients activities. The consultation itself has to be carried out in an appropriate form for all stakeholders. Grievance mechanism. This is the last step of the process, where all stakeholders (including general public) will have the fair opportunity to raise questions and concerns. These will be discussed in a respectable way and without unreasonable delay. 2. CATEGORIES OF STAKEHOLDERS & INFORMATION DISCLOSED 2.1 IDENTIFICATION OF STAKEHOLDERS Several stakeholder groups were identified that may be interested and/or affected by Qairokkum HPP project development and implementation. Identified stakeholders are internal stakeholders, such as Barki Tojiks employees and contractors workers, as well as external stakeholders, such as governmental authorities, private companies, non-government organizations and local residents: 1. Internal Stakeholders: BT and companies likely to be directly involved in the Project implementation 2. Regional and Local Authorities 3. Economic players interested by the Project without being directly involved in its implementation 4. General Public and Non- Governmental Organisations (NGOs) The table below provides a matrix for a potential stakeholder engagement program and the intended communication process, which contains the points of providing stakeholders details, communication methods and possible media that will be used for information disclosure. Page 2

No. Category of Stakeholder Information relevant to the respective Category Communication method & media 1.) Internal Stakeholders 1 Employees - General information about the project implementation and timeline (in the form of a nontechnical summary) - Impact of the project on the employee s work - Opportunities for new positions - Information about work safety - Instructions on environmental protection, occupational health and work safety 2 Construction workers, subcontractors, suppliers, consultants 2.) Regional and local authorities: - General information about the project implementation and timeline (in the form of a nontechnical summary) - Instructions on environmental protection, occupational health and work safety - Business opportunities (tenders, procurement ) - Personal communication - Bulletin board - Work safety and environment: regular training - Intranet - Other? - Personal communication - Information contained in the contracts - Call for proposals advertised on BT website 1 Administration of Qairokkum City 2 The Ministry of Agriculture of the Republic of Tajikistan 3 The Ministry of Land Reclamation and Water Resources of the Republic of Tajikistan (responsible for irrigation of lands) - The purpose of the nature and scale of the project - The duration of proposed project activities - Information about all envisaged consultation process, if any, and opportunities and ways in which the public can participate - Personal communication - Special public meetings / hearings to inform the public? - See above - Invitation to the Public Hearing / Meeting, if planned - See above - Invitation to the Public Hearing / Meeting, if planned 4 Department of Environmental Protection of Qairokkum City of the Environmental Protection Committee under Government of Tajikistan - Any risks to and potential impacts with regard to environment, worker health and safety, public health and safety and other social impacts on communities, and proposed mitigation plans - Personal communication - Invitation to the Public Hearing / Meeting, if planned - Any information necessary under the reporting needs (including Ecological Passport, State Ecological Expertise) 3.) Economic Players: 1 Company Sughd Mohi (engaged in fish industry) - The purpose of the nature and scale of the project - The duration of proposed project activities - Information about all envisaged consultation process, if any, and opportunities and ways in which the public can participate - Website - Invitation to the Public Hearing / Meeting, if planned Page 3

4.) General public & Non-Government Organizations (NGOs): 1 Citizens of Qairokkum and neighboring cities - The purpose of the nature and scale of the project - The duration of proposed project activities - Information about all envisaged consultation process, if any, and opportunities and ways in which the public can participate - Any risks to and potential impacts with regard to environment, worker health and safety, public health and safety and other social impacts on communities, and proposed mitigation plans 2 NGOs - The purpose of the nature and scale of the project - The duration of proposed project activities - Information about all envisaged consultation process, if any, and opportunities and ways in which the public can participate - Any risks to and potential impacts with regard to environment, worker health and safety, public health and safety and other social impacts on communities, and proposed mitigation plans 3 All stakeholders - In application of Aarhus convention and EU Water Framework Directive objectives, share with the public environmental data monitored at the dam site (for example outflow, water quality, water level, meteorology ) - Communal bulletin board - Website - Invitation to the Public Hearing / Meeting, if planned - Website, mailing - Personal communication - Invitation to the Public Hearing / Meeting, if planned - Share monitored parameters automatically on BT's website Tab. 1: Matrix for the Stakeholder Engagement Program for the rehabilitation of the Qairokkum HPP Qairokkum HPP is reporting on a regular basis a set of environmental data - see for instance the Ecological Passport (Паспорти экологи / Экологический паспорт) and the Report on Standards of Maximum Permissible Emission into the atmosphere by the Kayrakkum HPP (State Environmental Expertise (Лоихаи меъёрхои хадди имконпазири партов (ХИП) ба хавои атмосфера барои Неругохи барки обии Кайроккум). Barki Tojik will publish these data on its website environmental data for the Qairokkum HPP on a dedicated webpage, together with the following parameters: water level, water flow, eventually meteorological parameters. 3. VULNERABILITIES In the course of the development of the Environmental and Social Appraisal no special vulnerable groups, that would be affected by the rehabilitation (e.g. ethnic minorities, refugees, informal users ) have been identified. 4. GRIEVANCE MECHANISM 4.1 OBJECTIVE The objective of a grievance procedure is to ensure that all comments and complaints from any project stakeholder, including local/regional authorities, residents of nearby residential areas, BT employees, BT contractors staff and other interested parties, are considered and addressed in an ap- Page 4

propriate and timely manner. All grievances will be acknowledged and responded to within a reasonable timeframe. Examples of Grievance issues may include items such as: Noise, dust and truck traffic during dam rehabilitation works Impact on fishery industry during rehabilitation works at the dam and/or powerhouse Lack of timely response to input given during the project Barki Tojik has a department for registering complaints and proposals from the public on the power supply issues and other activities of the company s responsibility. Complaints and proposals are recording in special journal log and transferred to the responsible departments to resolve the issues. Subsequent to the results of reviewing the issue, the person who sent a complaint will receive an official response. Also there is a telephone hotline, which is published on press and television, any citizen of Republic of Tajikistan can contact with this phone number with his complaint and it will be investigated. All grievances will be registered and acknowledged within 5 days and responded to within 20 working days. BT will keep a grievance log and report on grievance management, as part of annual project progress reports, available at the BT website and on request at the BT office in Dushanbe. Comments and concerns regarding the project can be submitted in writing in the following ways: 1. In electronic form on BT website: www.barqitojik.tj 2. Via email: elrpbt@gmail.com 3. Via post: 734026 г. Душанбе, ул. Исмоили Сомони, 64; 4. Via fax: (+99237) 235-86-92; 5. Via phone: (+99237) 235-86-68; Individuals who submit their comments or grievances have the right to request that their name has to be kept confidential. During rehabilitation works of the HPP, grievances in relation to rehabilitation activities will be managed by the BT and the construction contractor. Residents will be informed about the contractors contact information before construction begins, through the local media (listed in the table above) and announcements in public places. A separate grievance mechanism is available for workers, both employees of HEP and the contractors. Page 5

4.2 RESPONSIBILITIES Stakeholder Liaison Officer at BT will have the overall responsibility for handling the consultation and information disclosure process, including organization of consultation process, communication with identified stakeholder groups, collecting and processing comments/complaints, and responding to any such comments and complaints. Depending on the nature of a comment/complaint, some comments or complaints will be provided to the appropriate person in the company for a response within 10 calendar days. BT will keep a record of all complaints and answers provided. Page 6

4.3 COMMENTS AND COMPLAINTS SAMPLE FORM Reference No: Full Name Comments and Complaints Sample Form FORM FOR COMMENTS, COMPLAINTS AND REPORTS OF INDIVIDUALS Contact Information and Preferred method of communication By Post: Please provide mailing address: Please mark how you wish to be contacted (mail, telephone, e-mail). By Telephone: By E-Mail: Description of Incident or Grievance: What happened? Where did it happen? Who did it happen to? What is the result of the problem? Source and duration of the problem? Date of Incident/Grievance One time incident/grievance (date ) Happened more than once (how many times? ) On-going (currently experiencing problem) What would you like to see happen to resolve the problem? Signature: Date: Page 7

(III) Environmental and Social Action Plan Qairokkum HPP Rehabilitation Phases 1 & 2, Tajikistan 0 Prepare and submit reports on the status of the implementation of the ESAP and environmental, social and occupational health and safety performance of the project as well as other relevant agreed activities. EBRD PR 1 - During construction each six months - During operation annually Submission of reports on the implementation of the ESAP and the Project s environmental, social, and occupational health and safety performance in form and substance satisfactory to EBRD. The Report Format is to be provided by EBRD. 1 PR 1: Environmental and Social Appraisal and Management 1.1 Develop and implement environmental, social, and occupational health and safety management systems equivalent to those under ISO 9001, ISO 14001, OHSAS 18001 (see also item 2.3) for all relevant departments and services of Qairokkum HPP. A three steps process is thus suggested: Best international practice; EBRD PR 1, 2 - Step 1: 2016 - Step 2: first full year (2017) - Step 3: 2018 and throughout loan duration - Systems developed by qualified person, staff trained, systems implemented. - Status reported in respective reports to EBRD Step 1. BT to make resources (staff, budget, training and/or external consultant...) available for the E&S management systems setup: year when the loan becomes effective (probably 2014) - Maintain system throughout operation phase Step 2. Develop the Environmental and Safety Management Systems Step 3. Certification (Q1 2016) and implementation (loan duration) 1 Items required to be reported to the Bank will be presented in the semi-annual or annual reports required under item 0, unless noted otherwise. Page 1

1.2 Appoint responsible manager(s) at Qairokkum HPP for (i) overseeing occupational health and safety issues, (ii) implementing environmental, social, and occupational health and safety management systems as per action 1.1 and (iii) following-up and reporting on the implementation of the ESAP as per Action 0. The person(s) shall report directly to the site manager and subsequently to BT management. Best international practice; EBRD PR 2-2016 and ongoing - Appointment of qualified person - Qualifications submitted with first report under item 0 - Responsible person maintained at all times 1.3 Train foremen, relevant staff and (sub-)contractors on each construction team and operational shift in the relevant requirements of this ESAP. Best international practice; EBRD PR 1 - Before construction starts (internal staff) - Before a new (sub)- contract starts (external staff) - Documentation of regular training for foremen, staff and other personnel (number and percentage of staff trained to be reported) - Include updates of training within regular reports to EBRD Page 2

1.4 Establish and implement corporate policy and procedures for oversight of (sub-)contractors in respect to environmental, occupational health and safety, and social performance during construction. This includes three different items: Item 1: Inclusion of appropriate ESAP and other legal requirements in contracts/subcontracts, including requirement for staff/management training. Best international practice EBRD PR 1 - Upon entry into contracts/ subcontracts - Prior to contractor actions Include in reports to Bank, for each contract passed under the Project: (i) contract title and short description, (ii) confirmation that CESMP was required within bidding documents, (iii) confirmation that CESMP was proposed by the selected contractor and was reviewed for approval by BT; Step A. BT includes in bidding documents for contractors a requirement for a CESMP (Construction E&S Management Plan) to be submitted with the technical proposals and separately quoted in the financial proposals. The CESMP should at least address all issues raised in the E&S appraisal (noise, dust and air quality, waste management, spill prevention and management, water-bodies protection...) and standard OHS requirements (risks review and prevention plan, OHS organization and management, PPEs, Emergency procedures). Step B. The CESMP is then to be reviewed by BT at the bid evaluation stage and agreed at the contract negotiation, with a provision for modifications based on a continuous improvement approach during the execution of works (iv) Highlights of contractor's EHS performance based on contractor's report; (v) Training: topics and number of people trained. Item 2. Assignment of clear responsibilities within BT on contractor oversight and performance monitoring. Item 3. Contractor reports on performance sufficient to allow inclusion of data in reports to the Bank, and to allow BT to determine if corrective actions are needed. See also item 2.3 (Occupational Health and Safety), as well as item 3.1 (Waste Management Plan), and item 4.1(Public Health & Safety). Page 3

1.5 Acquire and comply with all required permits and authorizations from respective Tajik ministries and authorities, including requirements from the State Ecological Expertise (SEE) as per the State environmental expert review N 735-15 dated 29/08/2013. 1.6 BT and it s contractors shall monitor: - if works requiring significant movement of materials (more than 1000 tons per day) are undertaken: a) air emissions (air quality) from Trucks and machinery exhausts, using exhaust measurement devices; - if works requiring significant traffic on public roads (more than 50 vehicles passing per day) are undertaken: b) noise (near settlements, if applicable), using portable sound level meters; - if works presenting a risk of spill/discharge of solid or liquid products to water bodies are undertaken: c) Permanent visual monitoring during the activity with immediate stop of the works when a spill/discharge is about to occur or occurs. Tajik laws and requirements EBRD PR 1 EBRD PRs, and international best practice Prior to beginning any activities that require permits or authorizations and during the whole loan duration. To be documented in annual reports. During construction - All permits and authorizations received - Reports submitted to authorities as required - Compliance status reported to EBRD Report to EBRD on highlights of implementation Page 4

1.7 Develop emergency response plan to cover at least flood response, fire, spills, severe injuries or fatalities, or other events that could reasonably be expected to occur within the lifetime of the power plant. This action has to be aligned with the Tajik legislation, where emergency plans are under the responsibility of the ministry of emergency situations. The ERP should therefore include: (i) inundation maps to be shared with the authority in charge of emergency situations Best practice Emergency response plan ready by end 2017 - Hire a consultant to prepare the emergency response plan - BT to review and approve the plan in consultation with responsible authorities and communities - Report to EBRD on status of planning and any updates - Report to EBRD immediately after emergency response actions are taken (ii) a set of operational procedures for the staff to manage the emergency (who to call, what to do...). The legal possibility for Qairokkum management to inform directly downstream structures (Farkhad and Shardara) is to be checked and would be a plus. 1.8 Low fish mortality to be included in the detailed design and procurement stages. The "low fish mortality" assessment should be based on the following: - review of the size and species of exposed fishes: present mortality rate of fish approaching the turbine intake taking into account the existing protections (grids, intake depth, etc ) and risks (cuts by turbine blades, rapid pressure variations) - definition of a target mortality rate for fish approaching the turbine intake associated with technical measures to be included in the Project: low mortality turbines, physical protections 2 PR 2: Labor and Working Conditions International Best Practise During specification of procurement requirements - "low fish mortality" assessment report shared with EBRD - Implementation of the required measures included in regular reporting to EBRD Page 5

2.1 Develop / update HR Policy and Procedures to fully comply with national law and EBRD requirements; Make this policy and Procedures available to employees in their language. 2.2 Develop a formal grievance mechanism for employees and contractors and disseminate information about its uses to the workforce, in the language(s) of the workers 2.3 As far as allowed by the Tajikistan legislation, support local labor force by: - Employing local workers where possible: establish and meet goals for local hires, consider training for permanent positions - Emphasis is laid on the need for legal employment only (no hiring without contract, even if for one day). This applies also for recruitment done by contractors. - Providing realistic information on employment opportunities, with transparent hiring practices - Advertise for all open positions - Paying wages at least average for the area for comparable positions 3 PR 3: Pollution Prevention and Abatement Tajik laws and requirements EBRD PR 2 EBRD PR 2 Tajik Law; EBRD PR 2; Best international practice Continuously From start of construction throughout operation phase - Submission of HR Policy and Procedures to the EBRD for review - Include in report to Bank data on workers, including dismissals and new hires, collective bargaining developments, status of medical checks, etc. - Report to EBRD the numbers of workers in various categories (management skilled unskilled, local non-local expatriate, women men) - Availability of policy and procedures for workers - Submission to EBRD of grievance procedure for review and approval - Thereafter, report to EBRD to include all worker grievances and resolutions Prior to workforce selection - Local announcements when hiring - Training for local workers - Wages comparable to regional averages Page 6

3.1 Develop and/or maintain a comprehensive waste management plan for the Qairokkum HPP for all wastes, including chemicals, fuel, oil, construction debris, domestic/household solid wastes. Ensure all off-site management is by licensed companies and in licensed places. The plan should include at least: - Procedures for proper handling of all waste generated at the HPP and construction sites, including especially bentonite and concrete slurry - Methods to verify proper off-site management of BTrelated wastes by contract waste managers - Measures to minimize waste generation and maximize reuse and recycling at the HPP. We suggest to utilize this waste management plan not only for the work period, but for practical reasons for all relevant Qairokkum HPP activities; thus it should be included in the procedures that will be prepared under future ISO 14001 preparation (see also item 1,4). Law of the Republic of Tajikistan on Ecological Expertise with amendments signed by the President of the Republic of Tajikistan dd. 16.04.2012, 818 rehabilitation works at the Qairokkum HPP fall under article 14 Best international practices; EBRD PR 1 & 3 Prior to construction activities. Collection of different types of wastes separately (i.e. hazardous wastes, dyes, domestic wastes etc.) will be supplied by the project developer or subcontractor. Development of the plan: - Review and/or approval of plan by authorities, if required - Require compliance in all contracts - Report to EBRD on status of plan and approval Implementation: - All wastes managed in accordance with approved plan - Reports to authorities as required in permits - Reports to BT by all contractors on amounts, types, and management of all solid wastes - Reports to EBRD on amounts, types, and management of all solid wastes (by BT and all contractors) - Immediate report to EBRD and relevant authorities of significant incidents and response actions Page 7

3.2 Develop and implement plan for transport, storage and management of excavated material from the earth-fill dam, concrete dam and other excavations. This shall include as a minimum: - Temporary on-site storage kept to a minimum and in secure location - Maximize beneficial use as fill, or otherwise as approved - Dispose in secure and authorized locations Best international practices; EBRD PR 3 Prior to excavation - Review and approval by authorities of management plan - Report to EBRD on plan approval and implementation, including amount of material handled and managed, methods, etc. - Report to authorities as required by permits No excavation spoils or quarries should be left uncovered after the project is implemented. Therefore, seeding or re-vegetation has to be implemented on the surfaces that would otherwise be left to erosion after the works are completed. If temporary only spoil dumps are to be used, then temporary covers are to be provided. 3.3 BT and it s contractor(s) shall implement air quality management practices to control construction dust and vehicle emissions, including (at a minimum): - Periodic observation monitoring for visible dust near construction/ traffic areas - Implement dust suppression as needed in dry/dusty conditions (water, gravel, etc.) - Maintain vehicles/equipment in good running condition - Cover loads as needed to prevent dust Tajik Law; EBRD PR 3; Best practice 1. Dust: WHO) Air Quality Guidelines & Directive 2008/50/EC Ambient Air Quality and Cleaner Air for Europe; 2. General EHS Guidelines: Environmental Noise Management of IFC Develop: prior to construction; Implement: throughout construction Report to Bank on monitoring results and highlights of dust control/ suppression activities Page 8

3.4 BT and it s contractor(s) shall implement measures to prevent / reduce / control impacts to groundwater and surface water as a result of spills of fuel, lubricants and other chemicals: - Store fuels and oils away from water in bonded containers with sufficient capacity - Ensure drip-trays are in place where fuels or oils are stored or used. - Identify a designated bonded refueling location - Train drivers and equipment operators in proper fuel management. 3.5 BT and it s contractor(s) shall be prepared for cleanup of small spills (fuel, etc.), including (but not limited to): - Spill control measures provided in all vehicles and equipment and at all sites at all times - Training in cleanup for drivers and equipment operators, and others who use fuel, oil, other hazardous materials - Inspections of vehicles and equipment for leaks before use near or in water. - Collection of waste water in pump sump and cleaning in waste water recycling plant prior to release back into the river 3.6 BT and its contractor shall implement a wastewater management plan Best international practices; EBRD PR 3 Best international practices; EBRD PR 3 Tajik Law and international requirements Best Practice (General EHS Guidelines: Wastewater and Ambient Water Quality of IFC) Throughout construction Throughout construction Before construction - Mitigated adverse impacts on local groundwater and surface water - Report to EBRD immediately in case of major incident - Report minor spills in regular reports to EBRD - All spills cleaned up promptly - Include in regular report to EBRD information on spills and cleanup - Include information about performance of waste water recycling plant - Target: Maintaining of Syr Darya River Water Quality - Positive results of monitoring reports regarding the implementation of Wastewater Management Plan Page 9

3.7 Asbestos: identify (location and volumes) asbestos containing material and include their removal in the Project. Include in the terms of reference of the contractor in charge of asbestos removal the following requirements:: Asbestos removal to be done by trained workers, with relevant protection equipment ; Procedure for transport and landfilling to be prepared and submitted to BT. Transport and landfilling of asbestos material in compliance with the Tajik regulation and in line with the objectives of the EU Directive 1999/31. Best international practices; EBRD PR 3 During the tender documents preparation and during rehabilitation works - Indication of the location of asbestos containing material :BT - Inclusion of relevant requirement in the tender documentation: design engineer - Removal: Contractor The procedure must be included in the requirements of the company with an objective to limit the dispersion in the environment and the exposure of workers and public to the asbestos fibres in compliance with the European legislation of dangerous waste (Directive 1999/31) 4 PR 4: Community Health & Safety and Security Page 10

4.1 Require contractors to implement -- procedures to protect public health and safety (see also item 1.4), which will include: - Traffic management plan for all drivers and equipment operators (speed limits, training, routes to follow, avoidance of sensitive areas) - Public notice of construction operations near areas open to the public - Security as needed to prevent unauthorized access to project locations, with appropriate training for guards - Notice to local authorities and nearby residents before major activities and traffic - Hazard notices/signs/barriers to prevent access to energized components and other dangerous areas - Make best effort to minimize disruption and closures of public roads Best international practices EBRD PR 4 - Develop procedures: prior to commencement of major works - Implement: throughout construction - Consultations with local authorities on traffic, notices, etc. - Consultations with traffic authorities on traffic plan - Submission of plans to EBRD with first report under item 0 - Report to Bank on traffic management, security, other activities, including any incidents/ accidents involving the public 10 PR 10: Information Disclosure and Stakeholder Engagement 10.1 Implement Stakeholder Engagement Plan to inform the public, receive comments and input on the project impacts, including stakeholder grievance mechanism and notice to authorities and residents of major construction events as well as to inform the public. This includes the disclosure on a dedicated page of BT's website of E&S information. In particular, the environmental parameters (water flow, water level and optionally meteorological parameters) that will be monitored in the frame of the new monitoring system should be disclosed on BT's website. Best international practices; EBRD PR 10 Throughout construction and operation - Include in regular report to EBRD on consultation activities, including notices given - Include in regular report to EBRD on all grievances received and how addressed/ resolved - Dedicated webpage ready in 2015, with water flow/level data disclosed on real time as soon as the monitoring system is set-up. Page 11

10.2 Report on a regular basis to the impacted communities about project progress status and about progress of this ESAP implementation Best international practices; EBRD PR 10 Throughout construction and operation - Include in regular report to EBRD on consultation activities - Report to communities on status Page 12